https://www.taxtmi.com/caselaws?id=310693 The ITAT PUNE held that an assessment order passed under section 144 read with section 153C was invalid due to lack of proper satisfaction recording. The Department failed to produce the satisfaction note from the AO of the searched person or demonstrate that proper satisfaction was recorded before handing over documents to the assessee's AO. Despite multiple opportunities, the Revenue could not produce the required satisfaction note or assessment records, claiming they were too old. The Tribunal ruled that the onus was on the Revenue to prove proper satisfaction was recorded, and failure to do so vitiated the assessment order, making it bad in law. The assessee's appeal was allowed. en-us Wed, 14 Nov 2018 00:00:00 +0530 Tue, 07 Nov 2023 21:48:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310693 The ITAT PUNE held that an assessment order passed under section 144 read with section 153C was invalid due to lack of proper satisfaction recording. The Department failed to produce the satisfaction note from the AO of the searched person or demonstrate that proper satisfaction was recorded before handing over documents to the assessee's AO. Despite multiple opportunities, the Revenue could not produce the required satisfaction note or assessment records, claiming they were too old. The Tribunal ruled that the onus was on the Revenue to prove proper satisfaction was recorded, and failure to do so vitiated the assessment order, making it bad in law. The assessee's appeal was allowed. Case-Laws Income Tax Wed, 14 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310693